"The Greenthread Patents cover foundational semiconductor technologies in the design and manufacture of integrated circuits such as memory, including but not limited to DRAM and NAND flash, and image sensors. Specifically, the Greenthread Patents describe semiconductor devices that employ graded dopants and well regions for, e.g., creating electric fields for aiding and/or retarding the movement of carriers to and/or from the semiconductor surface to/from the semiconductor substrate."
Few patents mentioned in the filing list G. R. Mohan Rao as an inventor:
US8421195B2 “Semiconductor Devices with Graded Dopant Regions”
US8106481B2 “Semiconductor Devices with Graded Dopant Regions”
US9647070B2 “Semiconductor Devices with Graded Dopant Regions”
The filing has an interesting info about Samsung S5K2X7SP sensor that allegedly infringes on the '070 patent above. This is fairly modern 24MP 0.9um Tetracell sensor featuring DTI, vertical transfer gate (VTG), and many other recent innovations from Samsung:
"Upon information and belief, the Accused Image Sensor Instrumentalities are in relevant part substantially similar to the exemplary S5K2X7SP CMOS image sensor, in particular with regard to the manner in which the Accused Image Sensor Instrumentalities include and utilize regions with graded dopant concentrations. Upon information and belief, Samsung fabricates the Accused Image Sensor Instrumentalities according to processes that utilize substantially similar process steps, including process steps for creating regions with graded dopant concentrations."
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